Can you barter for the cost of ad production?
I work in a small bank and our compliance officer is no longer with us, is there a list of compliance training that we are required to do each year with our employees. I am getting into the compliance end of operations and need some guidence till I can get some training.
Is it allowable to xerox a person's driver's license photo? Some tellers were doing this for non-customers cashing checks at our bank, but another employee says we cannot do that.
On scrolling electronic signs, when you advertise loans, does the "equal housing lender" logo have to be displayed?
In regards to HMDA Reporting. If a loan is for the purpose of home improvement and the term of the loan is less than 24 months is the loan HMDA reportable? HMDA is based on the purpose of the loan, not the term?
I relatively recently took a position as CEO with a small community bank ($45 million). Formerly, I was President of a $450 million bank. Needless to say, at a smaller institution, we all wear many hats. One of mine is CRA Officer and, since I had a dedicated person before, I'm rusty. I just read your entire section on the CRA regs. I want to be sure I'm not missing anything. As a small bank, is it really true that our total evaluation will be based solely on loan to deposit ratio, having the majority of our lending within our assessment area, reasonable distribution to low to moderate income individuals/families, reasonabel geographic distribution within our assessment area and prompt corrective action to any complaints? Is that really all? And, if we were graded "satisfactory" on those 5 elements, we'd have a crack at an "outstanding"? Small banks may elect to be evaluated on the lending, investment, service tests. Why would a bank want to do this if, as a small bank, they can elect to only be graded on those five areas? Ditto for submitting a Strategic Plan? Is there any benefit to a small bank in electing to be graded on either of these other two options? If, as we do, have a significant level of "service" and "investment" activities, do these get evaluated at all if we ultimately elect to be evaluated as a small bank? Can you give me some concrete examples of "Investments"? We currently participate in a local CEDE (Center for Economic Development) organization and are also involved in several minority organizations (Washtenaw County Homebuyers, POWER) with board positions, loans, agreeing to accept IDA's, participating in financial education seminars . . . are all those activities considered "Investment" activitiesor are there others I'm not recognizing? Other than the five elements of evaluation for a small bank, am I missing any other significant difference between how we would be evaluated and how a bank over 250 million would be evaluated? There seemed to be some di!fferences in data collection . . .please elaborate. Also, our bank is an 80% owner in a mortgage sub servicing company located in the Upper Peninsula of Michigan (we are in Ann Arbor)and that subsidiary also engages in originations. What kind of reporting do we need to be concerned about with the sub, if any, since all loans are sold into the secondary market? I thank you in advance for guidance and elaboration on this so I can relaunch our compliance with the CRA correctly for our small bank.
The Federal Reserve issued interim rules giving guidance for e-disclosures under Regs B, M, Z, etc. What about HUD? Can we, or can we not, provide RESPA disclosures electronically?